James J. and Linda J. Harford - Page 1

                                 T.C. Memo. 1998-392                                  

                               UNITED STATES TAX COURT                                

                    JAMES J. AND LINDA J. HARFORD, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 8436-97.                  Filed November 6, 1998.                

          James J. Harford, pro se.                                                   
          Linda A. Neal, for respondent.                                              

                                 MEMORANDUM OPINION                                   

          COUVILLION, Special Trial Judge:  This case was heard                       
          pursuant to section 7443A(b)(3) and Rules 180, 181, and 182.1               
          Respondent determined a deficiency of $5,457 in petitioners'                
          Federal income tax for 1994.                                                

          1     Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect for the year at issue.  All Rule            
          references are to the Tax Court Rules of Practice and Procedure.            

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